The BDA warns the regulator that this will do nothing to regain trust since the GDC's unlawful consultation on the annual retention fee (ARF) in 2014. It points out that the fee remains the highest of the UK regulators and continues to be used to top-up reserves that the profession deems to be inappropriate. The dentists' trade union has also insisted that before the GDC undertakes any other major work, it must significantly bring down dentists' ARF, with immediate effect from next year and make it clear to the profession how their fees are being spent.

The Association was pleased to see that the complex environment in which the dental profession operates has been acknowledged in the report, though it calls on the GDC to take a stand on the general practice contract in England, which is not fit for purpose and directly affects the ability of dentists to care for their patients. It also welcomes the scope for future work on complaint resolution, but asks the regulator to provide greater details on the plans.

The BDA calls on the regulator to allow registrants to pay the ARF by instalments and consider further ideas to support groups where the cost of registration is prohibitive, including new graduates, part time workers, refugee dentists, and those on maternity leave. The trade union also points out the value of introducing a 'non-practising' register, especially for retired dentists, who could, for instance, lend their expertise through mentoring or peer review arrangements.

BDA chair Mick Armstrong said:

"There can be no justification for keeping the ARF at its current rate. We have paid for the GDC's mismanagement in previous years – it's now time for the regulator to live within its means.

"The GDC is proposing to move away from consulting on an annual business plan to a 'high level' three-year strategy, with little or no scope to comment on the detail or the ARF. This raises questions around accountability when there is evidence that the GDC is using our fees to extend its remit.

"Co-operation has improved in some areas, but the GDC seems too willing to shut down a much-needed debate on GDC fees, efficiencies, reserves and spending of registrants' monies."